This Privacy Policy (this “Policy”) explains how Tornier protects your privacy when you use our Sites.

Effective Date:

This policy went into effect on 9/1/10.

Our Commitment to Transparency

We are committed to providing the information you need to make informed choices about the ways you use our Sites. This Policy describes the personal information we collect when you use our Sites, for example, by locating a distributor near you or by listing yourself as a qualified surgeon. It also describes how we use the personal information you share with us and some of the steps we take to protect your privacy.

In this Policy, “personal information” means information about an identified or identifiable individual. Examples of personal information include your name, your e-mail address, and your photograph.

If you have any questions about this Policy or our privacy practices, please contact us by e-mail at info@tornier.com.

Your Consent to This Policy

Please take a few minutes to review this Policy. By accessing or using our Sites, you are agreeing to the terms of this Policy. IF YOU DO NOT AGREE TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS SET FORTH IN THIS POLICY, PLEASE EXIT AND DO NOT USE OUR SITES.

This Policy is Part of Our Terms of Use

This Policy is part of the Terms of Use that govern your use of our Sites. A link to our Terms of Use is provided at the bottom of each page of our Sites.

This Policy May Change

As we add new features and functionality to our Sites, we may need to update or revise this Policy. We reserve the right to do so, at any time and without prior notice, by posting the revised version on our Sites. These changes will be effective as of the date we post the revised version on our Sites. They will apply only to the personal information we collect after we have posted the revised version. Your use of our Sites following any such change constitutes your consent to the terms of the revised Policy. For this reason, it is important to review this Policy regularly. If we modify this Policy, we will provide a notice at the top of this Policy for at least thirty days after the new effective date.

You may access the current version of this Policy at any time by clicking on the link marked “Privacy Policy” at the bottom of each page of our Sites.

Privacy Notices

This Policy may be supplemented or amended from time to time by privacy notices (“Privacy Notices”) provided at the time we collect your personal information. For example, certain pages of our Sites may contain Privacy Notices providing details about the personal information we collect on those pages, why we need that information, and choices you may have about the ways we use that information. Our Privacy Notices are part of this Policy.

Country-Specific Notices

Privacy requirements vary from country to country. To meet these requirements we may include certain “country-specific notices” as part of this Policy. If any of the terms of a country-specific notice are different than the general terms of this Policy, the terms of the country-specific notice will supplement or amend this Policy, but only to the extent that the laws of that country apply to the collection of personal information through our Sites.

Other Agreements

When you sign up to use a special feature of our Sites, you may be asked to agree to special terms governing your use of the special feature. In such cases, you may be asked to expressly consent to the special terms, for example, by checking a box or clicking on a button marked “I agree.” This type of agreement is known as a “click-through” agreement. If any of the terms of the click-through agreement are different than the terms of this Policy, the terms of the click-through agreement will supplement or amend this Policy, but only with respect to the matters governed by the “click-through agreement.”

What Personal Information Do We Collect When You Use Our Sites?

Information You Provide. We collect the personal information you knowingly provide (using your mouse and keyboard) when you use our Sites. The information we collect depends on how you use our Sites. For example:

If you search for a surgeon or distributor in your geographic area, we collect the contact information you submit.

If you apply for a job with Tornier, we collect your contact information and any resume you upload.

If you contact us through our Sites to request additional information, we collect the information included in your request.

Information Sent to Us by Your Web Browser. We collect information that is sent to us automatically by your Web browser. This information typically includes your IP address, the name and version of your operating system, the name and version of your browser, the date and time of your visit, and the pages you visit. Please check your browser if you want to learn what information your browser sends or how to change your settings.

This information does not identify you personally. Generally, we use this information to improve our Sites and make them more compatible with the technology used by our visitors. In most cases, we do not link the information sent by your browser to information that identifies you personally. However, there are some exceptions to this rule. For example, if you have created a user identity by signing up to use a password-protected area of our Sites, we may link your IP address to information that identifies you personally. We may also review our server logs — which contain visitors’ IP addresses — for security purposes, such as detecting intrusions into our network. If we suspect criminal activity, we may share our server logs with the appropriate investigative authorities who could use that information to trace and identify individuals.

Cookies and Similar Technologies. We use “cookies” and similar Web technologies to collect information and support certain features of our Sites. A cookie is a piece of Web code that is used primarily for one or more of the following: analysis of Web site traffic and user behavior, application functionality, and data storage. We use two types of cookies: “session cookies” and “persistent cookies.”

We use session cookies to assign a randomly generated unique identification number to your computer. Assigning your computer a number permits us to follow you as you move from page to page. A session cookies expires after you close your browser.

We use session cookies to collect statistical information about the ways visitors use our Sites — which pages they visit, which links they use, and how long they stay on each page. We analyze this information (known as “clickstream data”) to better understand our visitors’ interests and needs and to improve the content and functionality of our Sites. Session cookies do not identify you personally. If, however, you have created a user identity on a visit to one of our Sites, we may link the information collected by our session cookies to information that identifies you personally.

We use persistent cookies (cookies that do not expire when you close your browser) for several purposes. Like session cookies, they are used to assign a unique identifier to your computer, but because they are persistent, they permit us to recognize your computer each time you use it to access the Site. By using persistent cookies, we can collect and analyze clickstream data from more than one visit to the Site. Cookies are also used to store information you have previously provided such as your user identity or shipping address that can be displayed back to you automatically each time you visit the Site. Persistent cookies remain on your computer until you delete them or until they expire. Expiration durations vary and are set by Tornier and/or our third-party service providers.

Finally, both types of cookies (persistent and session) are occasionally used to facilitate the proper functioning of our applications and features of our Sites.

If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. You may also delete our cookies as soon as you leave our Sites. Although you are not required to accept our cookies when you visit our Sites, if you set your browser to reject cookies, you will not be able to use all of the features and functionality of our Sites.

How Do We Use Your Personal Information?

Generally. We use the personal information we collect through our Sites:

to provide the information, products and services you request;

for security, credit or fraud prevention purposes;

to provide you with effective customer service;

to provide you with a personalized experience when you use our Sites;

to contact you with special offers and other information we believe will be of interest to you;

to contact you with information and notices related to your use of our Sites;

to invite you to participate in surveys and provide feedback to us;

to better understand your needs and interests;

to improve the content, functionality and usability of our Sites;

to improve our products and services;

to improve our marketing and promotional efforts; and

for any other purpose identified in an applicable Privacy Notice, Country-Specific Notice, or other agreement between you and us.

Direct Marketing. Before we use your personal information for direct marketing purposes, we may offer you the opportunity to “opt out” or “opt in,” as required by applicable law. To learn more about the choices you have about the ways we use your personal information, please click here.

Employment Information. Some of our Sites include “careers” areas. When you use our Sites to search for job openings or apply for a position, we may ask you to provide certain personal information, such as your name, address, telephone number, e-mail address, educational background and employment history. You may also send us your resume and other information relating to your job search or application. We use the information you submit on the careers areas of our Sites for recruiting, hiring, and employment purposes, we do not use it for direct marketing purposes. More specifically, we use the information we collect through the “careers” areas of our Sites:

to respond to your searches and inquiries;

to process your job application and evaluate your qualifications;

to contact you regarding your application, for example, to arrange an interview;

to contact you with information about other employment opportunities we believe will be of interest to you;

to maintain our recruitment, applicant, and employee records;

to comply with applicable laws, such as equal opportunity laws; and

to improve our recruiting, hiring, and employment practices.

Please note that by submitting personal information to us through the careers area of one of our Sites, you authorize us to transmit and store your information in our recruitment database. We may also use this information in contacting references you provide or to obtain a consumer report regarding your criminal record. If you are hired by one of us, the information you provide during the recruiting process will become part of our employee records and may be used to “populate” or “pre-fill” data fields on password-protected sites used for human resource purposes, such as employee benefit administration sites. The careers areas of our Sites may be “powered” by a third-party service provider.

With Whom Do We Share Your Personal Information?

Service Providers. We may share personal information collected through our Sites with companies and organizations that perform services on our behalf, for example, companies that provide support services to us (such as online recruiting services and Web hosting services) or that help us market our products and services (such as third-party web analytics firms and marketing consultants).

Business Transactions. We may decide, for strategic or other reasons, to sell, buy, merge or otherwise reorganize one or more of our businesses. A transaction of this type may involve the disclosure of personal information to prospective purchasers. In such cases, we will take reasonable measures to protect the personal information we disclose, for example, by requiring the prospective purchaser to sign a non-disclosure agreement limiting the use and protecting the confidentiality of the personal information.

Business Transfers. Your personal information may be transferred to a company that has acquired the stock or assets of Tornier, for example, as the result of a sale, merger, reorganization or liquidation. If such a transfer occurs, the acquiring company’s use of your personal information will still be subject to this Policy and the privacy preferences you have expressed to us.

Compliance With Laws and Protection of Our Rights and the Rights of Others. We may disclose personal information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose personal information to prevent or investigate a possible crime, such as fraud or identity theft; to enforce or apply our online Terms of Use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.

As Described in a Privacy Notice. We reserve the right to disclose your personal information as described in any Privacy Notice posted on the Web page where you provide that information. By providing your personal information on that Web page you will be consenting to the disclosure of your personal information as described in that Privacy Notice.

As Described in a Country-Specific Notice. We reserve the right to disclose your personal information as described in any Country-Specific Notice posted on the Web page where you provide that information. By providing your personal information on that Web page you will be consenting to the disclosure of your personal information as described in that Country-Specific Notice

As Described in a Click-Through Agreement. We reserve the right to disclose your personal information as described in any click-through agreement to which you have agreed.

Your Choices

In General. We respect your right to make choices about the ways we collect, use and disclose your personal information. Therefore, we may ask you to indicate your choices at the time we collect your personal information.

Previously Expressed Preferences. You may change previously expressed preferences regarding how we use and share your personal information. If at any time you wish to be taken off our mailing lists, please contact us by e-mail at info@tornier.com. Please provide your full name, postal address and e-mail address so that we can find you on our mailing lists. Please give us a reasonable amount of time to honor your request.

How Can You Access, Update or Correct Your Personal Information?

Some of our Sites have links that permit you to access and update some of your personal information. In other cases, however, you will need our help. If you wish to access, update or correct your personal information, please contact us by e-mail at info@tornier.com. We will respond to you within a reasonable time and, in any case, within the time limits established by applicable law. We may ask you for additional information to verify your identity. In most cases, we will provide access and correct or delete any inaccurate information you discover. In some cases, however, we may limit or deny your request if the law permits or requires us to do so or if we are unable to verify your identify.

Security

How Do We Protect Personal Information? We take reasonable precautions to provide a level of security appropriate to the sensitivity of the personal information we collect. Although we use reasonable measures to help protect your personal information against unauthorized use or disclosure, we cannot guarantee the security of information provided over the Internet or stored in our databases.

Password Protected Areas of Our Sites. For your protection, certain areas of our Sites may be password protected. You are responsible for maintaining the confidentiality of your passwords. We have the right to assume that anyone accessing our Sites using a password assigned to you has the right to do so. You will be solely responsible for the activities of anyone accessing our Sites using a password assigned to you, even if the individual is not, in fact, authorized by you. If you have reason to believe that your password has been compromised or used without authorization, you must promptly change it using the functionality provided on our Sites.

Links to and from Other Web Sites

Our Sites may provide links to other Web sites operated by third parties. Because we have no control over third-party Web sites, we are not responsible for the availability of those Web sites and do not endorse and are not responsible or liable for any content, advertising, services, products, or other materials on or available from such Web sites. Tornier shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with the use of or reliance on any content, advertising, services, products, or other materials on or available from such Web sites. This Policy does not apply to your use of third-party Web sites; your use of such Web sites is subject to the terms and policies of the owner of such Web sites.

Children Under the Age of Thirteen

We are proud of our Sites and we strive to ensure that they do not offend people of any age. However, our Sites are not intended for children or minors under the age of thirteen years without the permission of a parent or guardian. If you believe that a child has submitted personal information on or through our Sites without the consent and supervision of a parent or guardian, please contact us by e-mail at info@tornier.com so that we can take appropriate action.

Information for Visitors Accessing our Sites from Outside the United States

Tornier is headquartered in the United States. The Sites governed by this Policy are hosted on servers located in the United States, although we reserve the right to relocate our Sites to other servers elsewhere in the world. Your personal information may be stored on servers located within the United States or in another country. In addition, we may transfer your personal information to our service providers and others located in the United States or another country for the purposes described in this Policy. Different countries have different privacy laws and requirements, and some provide less legal protection for your personal information than others. Please know, however, that no matter where your personal information is collected, used, transferred or stored, if it was collected through this Policy, it will be protected by the terms of this Policy and any Privacy Notices, Country-Specific Notices or other agreements that apply to you.

BY USING OUR SITES, YOU ARE CONSENTING TO THE COLLECTION, USE, AND TRANSFER OF YOUR PERSONAL INFORMATION IN OR TO THE UNITED STATES OR TO ANY OTHER COUNTRY IN THE WORLD SUBJECT TO THE TERMS OF THIS POLICY

Governing Law

This Policy is part of our Terms of Use and, as such, shall be governed under the laws of the State of Minnesota, United States of America, without regard to its conflicts of law provisions.

Questions Concerning This Privacy Policy

If you have any questions or concerns regarding this Policy, please contact us by telephone, e-mail, or postal mail: